You must examine a full range
of alternatives in the analysis documented in either an EIS or an EA.
Those alternatives carried forward for analysis must meet project objectives
to a large degree, although not necessarily completely. For instance,
in the example in section 2.5, you may
choose to add an alternative that analyzes using hotels in the town nearest
the north rim of the Grand Canyon, even if your project objective was
to provide an extended experience for visitors right at the rim. The alternatives
must also be developed with environmental resources (rather than cost,
e.g.) as the primary determinant. In other words, they propose different
means of accomplishing your parks goals, while at the same time
protecting or minimizing impacts to some or all resources. Keep in mind
that at this stage, the range of options you consider may not ultimately
be fully analyzed as reasonable alternatives, as explained
below.

B. Reasonable alternatives

CEQ
has defined reasonable alternatives as those that are economically and
technically feasible, and that show evidence of common sense (Q2a). Alternatives
that could not be implemented if they were chosen, or that do not resolve
the need for action and fulfill the stated purpose in taking action to
a large degree, should be eliminated as unreasonable before impact analysis
begins. Unreasonable alternatives may be those that are unreasonably expensive;
that cannot be implemented for technical or logistic reasons; that do
not meet park mandates; that are inconsistent with carefully considered,
up-to-date park statements of purpose and significance or management objectives;
or that have severe environmental impacts  although none of these
factors automatically renders an alternative unreasonable. CEQ is also
clear that agencies should not pare the list down to only those alternatives
that are cheap, easy, or your parks favorite approach. Rather, feasibility
is an initial measure of whether the alternative makes sense and is achievable.

In fact, CEQ has added language cautioning against
using even what may seem clear criteria for routinely dismissing alternatives
as unreasonable. For instance, if an alternative is any of the following,
but otherwise feasible, it must be included in the range of alternatives
(Q2b):

outside
the scope of what Congress has approved or funded.

outside
the legal jurisdiction of your park.

undesirable
to an outside applicant but reasonable to the park.

in
conflict with a law.

outside
those alternatives provided for by a GMP or other park planning document
(particularly if the plan or policy is older or no longer applicable
to the issues the park is now facing (1500.1 (a)).

These conditions often are obstacles to implementing
an action, because a law may need to be changed, an applicant may need
to modify a proposal, or Congress may need to rethink approval or funding.
However, CEQ notes that the EA or the EIS analyzing such alternatives
may serve as the vehicle for such change.

Alternatives may also be eliminated as unreasonable
as the NEPA process progresses. For instance, if initial impact analysis
shows that a technically or economically feasible alternative would have
profound adverse environmental impacts, it should be eliminated as environmentally
infeasible.

EAs and EISs should include a section discussing those
alternatives that were considered but rejected and briefly explain the
reasons for their elimination.

C. No action

The no action alternative is developed
for two reasons. It is almost always a viable choice in the range of reasonable
alternatives, and it sets a baseline of existing impact continued into
the future against which to compare impacts of action alternatives. This
is important context information in determining the relative magnitude
and intensity of impacts (see also, section 4.2(a)). If choosing the true
no action alternative (i.e., continuing as is) would violate laws or your
parks own policies, you may want to add a minimum management
alternative to your range. This should not substitute for the no action
alternative, because you may lose valuable information on existing impacts
by not evaluating the impacts of ongoing activities.

No
action for plan modifications  As a rule, for GMPs, assume the
no action alternative would continue present management actions. No
action then becomes an accurate baseline to compare against action alternatives.
As allowed by CEQ (Q3), you may group all existing plans and policies
into an alternative to show the impacts of implementing them in the
future. This alternative should be considered one of the action alternatives,
rather than no action.

No
action for a project  This would mean the proposed activity would
not take place (Q3). Therefore, no action is the continuation of existing
conditions and activities without a particular planning context.

Impacts
of no action  The impacts of no action are the impacts of existing
activities or conditions (man-made or natural) projected into the future.
If the proposal is to modify a plan, the impacts are the impacts of
the unmodified plan. The impacts of no action help readers understand
whether the project would degrade or improve conditions in an already
degraded environment, or in a relatively pristine one. Analysis of no
action must also include the cumulative impacts of all past, present,
and reasonably foreseeable actions.

If the proposal is to improve existing conditions,
the impacts of no action are particularly important to describe, because
they help to define the need for NPS action. If implementing the no action
alternative would result in predictable actions by others,
this impact should be part of the effects of no action (Q3).

Impacts of no action help decision-makers understand
the comparative impacts of proposals, as well as the absolute impact.
For instance, if your park is analyzing the impact to wildlife of a proposal
to add a trail in an area already covered with trails, the impacts to
wildlife of no action (e.g., from hikers using the trails) are distinctly
different from the impacts if this were the first trail into a wilderness
area. Compared with the existing impacts, a new trail in the first case
may have less of an impact than in the second.

Impacts of no action also provide an assessment of
absolute, or total, impact to a resource. In the example above, the impacts
of the proposed trail, when added to those of existing trails (no action),
may impose greater impacts on wildlife than a single trail in a wilderness
would.

Accurately and completely describing the impacts of
existing sources  that is, of continuing actions
 is critical to understanding the context, duration and intensity
of new impacts. For this reason, a full analysis of no action is required
in all NPS EISs and EAs. This is true even when your park is under legislative
or other command to take action (Q3).

After the environmental analysis is completed, you
must identify the environmentally preferred alternative or alternatives.
Descriptions of these alternatives must be included as a separate heading
at the end of the alternatives section of the document. The environmentally
preferred alternative is the alternative that will promote the national
environmental policy expressed in NEPA (Sec. 101 (b)). This includes alternatives
that:

fulfill
the responsibilities of each generation as trustee of the environment
for succeeding generations.

ensure
for all Americans safe, healthful, productive, and esthetically and
culturally pleasing surroundings.

attain
the widest range of beneficial uses of the environment without degradation,
risk of health or safety, or other undesirable and unintended consequences.

preserve
important historic, cultural, and natural aspects of our national heritage
and maintain, wherever possible, an environment that supports diversity
and variety of individual choice.

achieve
a balance between population and resource use that will permit high
standards of living and a wide sharing of lifes amenities.

enhance
the quality of renewable resources and approach the maximum attainable
recycling of depletable resources.

Simply put, this means the alternative that causes
the least damage to the biological and physical environment; it also means
the alternative which best protects, preserves, and enhances historic,
cultural, and natural resources (Q6a). In the NPS, the No Action
alternative may also be considered in identifying the environmentally
preferred alternative.

Through identification of the environmentally preferable
alternative, the NPS decision-makers and the public are clearly faced
with the relative merits of choices and must clearly state through the
decision-making process the values and policies used in reaching final
decisions.

E. Consistency with sections 101 and 102(1) of NEPA

As required under CEQ regulations 40 CFR 1502.2(d),
NEPA documents must include a section stating how each alternative analyzed
in detail would or would not achieve the requirements of sections 101
and 102(1) of NEPA and other environmental laws and policies. In the park
service, this requirement is met by 1) disclosing how each alternative,
one of which is identified as the environmentally preferred, meets the
criteria set forth in section 101(b) of NEPA (see above); and 2) any inconsistencies
between the alternatives analyzed in detail and other environmental laws
and policies.